Case Summary (G.R. No. L-33604-05)
Petitioner and Respondent
The petitioner is the People of the Philippines, represented by the prosecution, while the respondents are Jesus G. Ruiz and Alfredo Guno, who are appealing their convictions from the lower court.
Key Dates
- December 16, 1966: The incident leading to the charges occurred.
- July 15, 1970: The lower court's judgment was dictated, finding the accused guilty.
- October 30, 1979: The case was reviewed by the Supreme Court.
Applicable Law
The case is governed by the Revised Penal Code of the Philippines, specifically Articles 248 and 249, which outline the penalties for murder and frustrated homicide, respectively. The aggravating circumstance of nighttime, as noted in Article 14(6) of the Revised Penal Code, and the mitigating circumstance of acting in vindication of a grave offense are also considered.
Facts of the Case
On December 16, 1966, a confrontation occurred at a police station involving Jesus G. Ruiz and members of the Nasipit Police. A heated exchange between Ruiz and Sgt. Bito culminated in Bito, a police officer, challenging Ruiz to a draw. After Ruiz left the site angrily, he returned with other individuals, including Guno, later that evening. A violent confrontation ensued in which Bito was killed, and Felias and Galve were injured by gunfire. The prosecution contended that Ruiz fired the fatal shot that killed Bito.
Lower Court Proceedings
The lower court found Jesus G. Ruiz guilty of murder and Alfredo Guno guilty of frustrated homicide, taking into account aggravating circumstances connected to the nighttime and the lack of mitigating factors for both accused. Ruiz received a sentence of death by electrocution for murder, while Guno was sentenced to a lengthy term for frustrated homicide.
Arguments of the Accused
Both Ruiz and Guno appealed their convictions. Ruiz argued that the lower court erred in accepting the prosecution's evidence as credible, while Guno contended that he did not inflict harm on the victim and thus should not be liable as an accomplice.
Supreme Court’s Analysis
The Supreme Court upheld the lower court's decision regarding the credibility of the prosecution witnesses, noting the testimony of Libertad Bito Ruiz, who witnessed her uncle shooting Bito. The Court found substantial corroboration from other witnesses, including Patrolman Granada. The Court also rejected claims made by the defense regarding bias and the nature of the testimonies provided.
Conclusions
The Supreme Court modified the lower court's judgment, reducing the charges against both Ruiz and Guno. Instead of murder, the Court found Ruiz guilty of homicide due to the absence of treachery and evident premeditation. Guno was held liable as an accessory to Ruiz’s actions despite the lack
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Case Overview
- Decision Date: October 30, 1979
- Jurisdiction: Supreme Court of the Philippines
- Case Numbers: G.R. Nos. L-33604-05
- Lower Court: Court of First Instance of Agusan del Norte and Butuan City, Branch II
- Criminal Cases: Nos. 3323 and 3324
Background of the Case
- The case involves the prosecution of Jesus G. Ruiz and Alfredo Guno for murder and frustrated homicide.
- The incidents occurred on December 16, 1966, in Barrio Talisay, Nasipit, Agusan.
- The accused, along with others, allegedly conspired to attack law enforcement officers, specifically targeting Sgt. Alfredo Bito and Lt. Amado Felias, leading to Sgt. Bito’s death and the wounding of Lt. Felias.
Charges and Verdicts
Criminal Case No. 3323 (Murder):
- Jesus G. Ruiz and Alfredo Guno found GUILTY beyond reasonable doubt of murder under Article 248 of the Revised Penal Code.
- Sentenced to DEATH by electrocution.
- Ordered to indemnify the heirs of Sgt. Alfredo Bito for P12,000.00, P50,000.00 for actual and moral damages, P25,000.00 as exemplary damages, and P10,000.00 for litigation expenses.
Criminal Case No. 3324 (Frustrated Homicide):
- Both accused found GUILTY beyond reasonable doubt of frustrated homicide under Article 249, with the aggravating circumstance of nighttime.
- Sentenced to an indeterminate penalty of SIX (6) YEARS of prision correccional as minimum to TWELVE (12) YEARS of prision mayor as maximum.
- Ordered to indemnify Amado Felias for P12,000.00 in actual and moral damages an